2

Research Management at EPA

THE ROLE OF ORD

EPA's Office of Research and Development (ORD) conducts research in its in-house laboratories, funds extramural research at academic institutions and other organizations, performs a variety of activities in the development and application of risk-assessment methods and regulatory criteria, and provides technical services in support of the agency 's mission and its regulatory and regional offices. In fiscal year 1999, ORD had 1,976 staff members at 12 geographically dispersed laboratory facilities, three field stations, three assessment offices, and the headquarters office in Washington, DC. ORD also had an extramural research budget of about $315 million – more than half of its $559 million total budget in fiscal year 1999 – for grants, cooperative and interagency agreements, contracts, and fellowships. Over the past 20 years, the resources of ORD have generally comprised about 7% of the agency's total budget (Figure 2-1).

A great deal of scientific activity is conducted or funded by EPA offices outside ORD. This work is typically labeled as something other than “research.” The other offices of EPA do not have the kind of authorization that ORD has to conduct research per se, and full disclosure might risk the loss of control of some of these activities by the regulatory offices. Perhaps the existence of a substantial amount of research-



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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices 2 Research Management at EPA THE ROLE OF ORD EPA's Office of Research and Development (ORD) conducts research in its in-house laboratories, funds extramural research at academic institutions and other organizations, performs a variety of activities in the development and application of risk-assessment methods and regulatory criteria, and provides technical services in support of the agency 's mission and its regulatory and regional offices. In fiscal year 1999, ORD had 1,976 staff members at 12 geographically dispersed laboratory facilities, three field stations, three assessment offices, and the headquarters office in Washington, DC. ORD also had an extramural research budget of about $315 million – more than half of its $559 million total budget in fiscal year 1999 – for grants, cooperative and interagency agreements, contracts, and fellowships. Over the past 20 years, the resources of ORD have generally comprised about 7% of the agency's total budget (Figure 2-1). A great deal of scientific activity is conducted or funded by EPA offices outside ORD. This work is typically labeled as something other than “research.” The other offices of EPA do not have the kind of authorization that ORD has to conduct research per se, and full disclosure might risk the loss of control of some of these activities by the regulatory offices. Perhaps the existence of a substantial amount of research-

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices FIGURE 2-1 Comparison of EPA and ORD total budgets, 1980-2000. Source: EPA.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices like activity outside ORD is an indication that the agency's regulatory and regional offices believe that ORD is not fully meeting their scientific needs. In any case, it is problematic, because many scientific activities performed or funded outside ORD historically have not been well-coordinated across the agency and have not been included in the ORD research planning and peer-review programs. In response to a recommendation from our companion committee in this NRC study (NRC 1997), ORD and the EPA Science Policy Council, with the assistance of other EPA offices, began to develop in 1998 an agency-wide “inventory of science activities.” The inventory is intended to become an “evergreen” interactive planning tool to integrate a variety of scientific efforts within a common strategy. Organized according to the agency's strategic goals under the Government Performance and Results Act, the inventory holds promise as a tool to help improve scientific collaboration across agency offices and to identify scientific gaps and opportunities for consolidation. The first draft of the inventory is sketchy, containing only general information about the various activities and no information about resources or milestones. It is not yet well-documented or published. Agency work groups are working under the direction of the Science Policy Council to develop recommendations for improvement of the scope, purposes, and form of the inventory, as well as standards for collecting the relevant information. From time to time, the question arises whether EPA should have its own research program or rely on research results developed elsewhere. Advocates of having the research conducted elsewhere often cite past criticisms of the agency's research program and point to excellent research programs of other agencies and organizations, which collectively, and in some cases individually, dwarf that of EPA. Many other agencies and organizations certainly contribute much of the scientific and technical information that EPA requires. At the federal level, they include the Departments of Agriculture, Commerce, Defense, Energy, and Interior; the NIH; National Aeronautics and Space Administration; and NSF. NSF devotes about $600 million a year to environmental research – about the same as ORD's total budget – and recently, the National Science Board recommended a major expansion of NSF's environmental research, planning, education, and scientific assessment, with a funding target of an additional $1 billion over 5 years (NSF

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices 1999). The Department of Energy spends about $500 million a year on environmental quality research. Many public-health, environmental, and natural-resource agencies at the state and local levels also support scientific activities. Internationally, the World Health Organization, the International Agency for Research on Cancer, and many nations have strong scientific review and risk assessment programs. And, of course, the academic community and the private sector conduct much of the research relevant to EPA's mission. In Safeguarding the Future: Credible Science, Credible Decisions (EPA 1992), a panel of four senior academicians, including two members of our committee, was asked by EPA's then-administrator William Reilly for advice on how the agency could best meet the goal of using sound science for its decision-making. The panel concluded that “EPA needs its own strong science base to provide the background required for effective environmental protection programs.” The panel gave several reasons for this conclusion: EPA decisions frequently are controversial and affect broad sectors of society and the economy. Controversial decisions demand a strong science base when decisions are made. EPA cannot rely only on other government agencies to develop the scientific information it needs for decision-making. The existence of its own science base allows EPA to tie science to long-term regulatory objectives and other environmental protection strategies. Interaction between scientists and policy-makers is essential for sound decision-making. Some scientific activities, such as controlled human exposure studies, require special facilities that are beyond the capability of most university-based research programs. The NRC's Committee on Research Opportunities and Priorities for EPA – our companion committee in this study – also concluded that EPA needs a strong in-house research program (NRC 1997). Based on the extensive experience of members of our committee with the research program and applications of science in EPA (see Chapter 1), our committee agrees that a vigorous research program should be maintained in EPA. Moving the research program out of the agency would most likely weaken, not strengthen, the scientific foun

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices dation of EPA's decisions and actions. Although some abstract concept of scientific “quality” might be improved by reducing some kinds of ORD technical work that are unlikely to advance research frontiers, such work is often critically necessary to EPA's pursuit of its mission and statutory responsibilities. Overall, eliminating ORD or moving its functions out of EPA would be destructive, and the level of damage would increase with passing time as EPA became increasingly unable to pursue, apply, or even understand new research knowledge. An EPA devoid of a research program would not be likely to attract substantial scientific talent, and an EPA without the kind of scientific talent that research attracts could be ineffective and potentially harmful to the nation. However, ORD should recognize its limits and the need to depend on partnerships with other research organizations. ORD's resources are important, but only a small part of the total resources devoted to research relevant to environmental protection in the United States and abroad. Even with a much larger budget, ORD could never meet all of EPA's vast and constantly changing needs for scientific knowledge. ORD has had a first-rate research program in some important areas, such as aquatic toxicology and human inhalation toxicology, but it is not possible for ORD to conduct in-house research across the full range of scientific knowledge required by EPA. If ORD were to try to meet all of EPA's needs for scientific knowledge, it would dilute its research efforts on the most important problems and detract from critical core research needs. Careful choices need to be made in using ORD's important but limited resources to maximize the value it adds to the total reservoir of knowledge that is needed and disseminated within EPA, the scientific community, and other organizations. As recommended in Future Risk: Research Strategies for the 1990s (EPASAB 1988) and Building a Foundation for Sound Environmental Decisions (NRC 1997), EPA should focus on a few core research areas that it can handle well and rely on partnerships and outreach for other scientific needs. The agency should strive to stimulate and coordinate research at national and international institutions that is responsive to its needs. EPA should be a leader in some areas of research, involved in others, and well informed in all relevant areas. To accomplish that, EPA needs a cadre of scientists responsible for maintaining a thorough awareness in specific research areas that are important to the mission of the agency. It should develop a strong, structured approach to the re-

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices trieval, synthesis, and application of the results of research conducted not only by ORD, but also by scientists not affiliated with or supported by EPA. This includes research conducted or sponsored by other federal and state agencies, universities, and industries, both in this country and abroad. The internet presents great opportunities for enhancing interagency and international research coordination. Another important question asked from time to time pertains to the overall balance in EPA's research program. In a report accompanying EPA's appropriations for fiscal year 1993, the congressional conference committee requested EPA to review the balance between its basic and applied research, stating, The Committee believes that, for a number of reasons, EPA has failed to sufficiently address the issue of basic research. Due to the large number of regulatory and statutory mandates, the Agency has focused on short-term applied research. Basic research can be used to identify and assess environmental problems which pose the greatest risk to human health and the environment. ORD's strategic plan (EPA 1996a, 1997a) states, “While all of EPA uses science for policy and regulatory decision-making, and various EPA offices contribute to the scientific underpinnings of the Agency's decisions, the responsibility for leadership in science at EPA and for the bulk of EPA's research and development work resides in the Office of Research and Development.” Yet, EPA's statutory mandates and regulatory programs have historically been problem-driven, and consequently so has most of ORD's program. Strong demands are placed on ORD to meet the needs of the agency's regulatory programs. The difficulties of serving multiple regulatory-office clients while trying to sustain a core-research program have posed challenges to ORD throughout its history. ORD has continually been torn between competing demands: on the one hand, to lead, and on the other hand, to serve the rest of EPA. EPA acknowledged that difficulty in the preface to Fundamental and Applied Research at the Environmental Protection Agency (EPA 1994a): Indeed, the difficulty for EPA as well as for other regulatory agencies has been meeting the needs of many research clients. EPA's research program must strike a balance between providing data and technical

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices support for ‘front-line' regulators solving environmental problems today and building a science knowledge base necessary to manage our ecological resources wisely in the coming decades; understand how pollutants affect our health; and prevent or reduce environmental risks in the future. In Building a Foundation for Sound Environmental Decisions (NRC 1997), our companion committee in this NRC study recommended that EPA's research program maintain a balance of roughly equal proportions between problem-driven research, targeted at understanding and solving particular, identified environmental problems and reducing the uncertainties associated with them, and core research, which aims to provide broader, more generic information to help improve understanding relevant to environmental problems for the present and future. It described problem-driven research as the kind of research and technical support activity that ORD has pursued most in the past, efforts that are largely driven by current or anticipated regulatory efforts of other EPA offices. Problem-driven research is a means to understand single problems in depth and assess remedies. Core research is largely aimed at providing knowledge for the agency to anticipate and respond to current and future environmental problems. The 1997 report described three components of core research: Acquiring a systematic understanding of the physical, chemical, biological, geological, social, and economic processes that underlie and drive environmental systems, and the biochemical and physiological processes in humans that are affected by environmental agents. Developing broadly applicable research tools and methods for understanding and managing environmental problems, including better techniques for measuring physical, chemical, biological, social, and economic variables of interest; more accurate models of complex systems and their interactions; and new methods for analyzing, displaying, and using environmental information for science-based decision-making. Designing, implementing, and maintaining appropriate environmental monitoring programs and evaluating, synthesizing, and disseminating the data and results to improve understanding of the status of and changes in environmental resources

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices over time and retrospectively evaluating whether environmental policies are having the desired effects. The distinction between research in problem-driven and core areas is not always clear-cut, and the categories might often overlap. Fundamental discoveries can be made during the search for solutions to narrowly defined problems, and breakthroughs in problem-solving sometimes occur as a result of core-research efforts. Feedback between the two types of research greatly enhances the overall research endeavor. The goals of core research tend not to vary much over time, so coreresearch priorities will remain relatively constant. Problem-driven research, on the other hand, should be responsive to regulatory program needs and changing priorities, so it should be re-evaluated and refocused regularly. Our committee concurs with the 1997 NRC report and supports the increased priority and proportion of a core-research program in ORD. The core-research program should endeavor to emphasize the evaluation of potential environmental concerns and “over-the-horizon” possibilities (EPASAB 1995), as well as new approaches to managing current problems. Safeguards will continue to be needed to ensure that the important scientific needs of EPA's regulatory programs and regional offices are not unduly compromised. A great burden has been placed on the agency-wide strategic-planning process, discussed later in this chapter, to ensure that such compromise does not occur. ORD's technical support role should be planned and conducted with clear understanding of the goals of such support, the appropriate degrees of interaction with program office staff, and the timing and channels of such interactions. ORD's programs should address the needs of the agency in the context of a broad, comprehensive framework (e.g., Presidential/Congressional Commission on Risk Assessment and Risk Management 1997a,b). Our committee believes that ORD's overall program should Identify and define the risks to human health and the environment and develop scientific and technical approaches to reduce such risks. Demonstrate the feasibility of regulatory or nonregulatory risk-reduction actions that may be taken.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices Support and facilitate the development and implementation of necessary regulations aimed at reducing risk. Both the problem-driven and core components of EPA's research serve to support EPA's fundamental mission: to identify, assess, and abate risks to public health and the environment. Viewed in that context, the strategic mission of EPA's research program, in both the short and long run, is to develop and advance the scientific and technical basis for risk identification and assessment and to guide decision-makers in making risk-management judgments and selecting overall priorities. Many scientists within and outside the agency believe that ORD should become more of a pro-active leader for the rest of the agency, giving greater emphasis to anticipatory research that develops the knowledge to lead EPA into new strategies and levels of understanding. Regulatory officials, on the other hand, often argue that EPA's limited resources, including ORD's, are provided to support the agency's existing statutory mandates and regulatory programs, so ORD should provide the regulatory offices with more technical assistance and short-term, quick-payoff, applied work. Our committee is convinced, as was our companion committee (NRC 1997), that the core-research role is of crucial importance to EPA and the nation. The very nature of the problems faced by EPA has been changing dramatically, and surprises have become common. EPA was created in 1970 with the limited understanding of environmental issues available at that time, including some concepts that are now largely outdated and rapidly being subsumed in new concepts such as sustainable development and industrial ecology (EPASAB 1988; NAE 1994; NAPA 1994; OSTP 1994). These concepts envision the integration of environmental science and technology throughout the entire economy. They are not simply (or in many cases even primarily) concerned with reducing existing impacts or ensuring compliance with so-called “end-of-pipe” regulations. If ORD is to participate effectively in developing and implementing new concepts and policy directions, its scope of activities should be appropriately expansive. ORD should address not only the individual pollution-related problems that have traditionally concerned EPA, but also the research on complex topics such as sustainable development and biological diversity. Research should lead the activities of EPA and not just follow past policies or

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices respond to currently perceived needs. EPA's research should address future problems, not just past and present problems. Some research problems are sufficiently broad or complex that they can be addressed effectively only by a long-term focused effort. In addition, a sustained program of anticipatory research would be expected to reduce the need for reactive projects in many cases. An effective over-the-horizon research program seeks to anticipate and address future scientific needs in support of environmental protection, thereby reducing future needs for reactive efforts that are often less efficient and more expensive. Using ORD for short-term scientific assistance to regulatory and regional offices has some undeniably important benefits. Perhaps the greatest dividends are the resulting improvements in the scientific aspects of regulations, the maintenance of an in-house scientific core group experienced in dealing with environmental risks and programs, and the knowledge of agency issues that the research scientists obtain through such experience. An experienced scientific core group can be of great importance in meeting emergency requirements for scientific expertise. ORD's technical assistance provides the regulatory offices with competent scientific support, and it enables the ORD research scientists to keep abreast of regulatory and policy developments elsewhere in EPA. ORD should meet the continuing challenge to lead the agency through research while continuing to assist its client regulators, who have variable levels of understanding and appreciation of science but a strong say in ORD's budget and priorities. ORD's regulatory assistance activities often have a narrow focus and compete with or pre-empt long-term research programs. Such activities tend to consume the resources of a research organization disruptively as well as disproportionately. There is also some inevitable risk to ORD's scientific credibility when it provides technical assistance for regulatory strategies that might be predetermined, or are perceived to be. In addition, regulatory strategies, which are typically prescriptive and specific, tend to freeze concepts and methods in time. The scientific components of regulations also tend to be frozen in time. The more closely that ORD is tied to the regulatory programs, the greater the risk that ORD will work to some extent on outdated problems or with outdated approaches – waging the last war instead of preparing for the next one.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices THE 1995 REORGANIZATION OF ORD By the early 1990s, the structure of ORD reflected its historical origins, the traditional areas of strength of its laboratories, the technical-assistance requirements of the agency's regulatory programs, directives from Congress, the agency's research-mission ambiguities, and a culture of entrepreneurship in some parts of ORD. In 1993, EPA estimated that approximately 29% of ORD's total resources were devoted to “fundamental” research, 43% to “application-directed” research, 19% to “development,” and 9% to “technical assistance,” although it expressed uncertainty about how to define those terms (EPA 1993). As our committee began its work, EPA was making major changes in its research program. The process leading to those changes began in 1993 with a decision by the administrator, in response to a request of Congress, to evaluate all of EPA's laboratories in relation to the agency's scientific and technical needs. The first major step in the evaluation was a study by the MITRE Corporation, working with a team of EPA officials, and with assessments by EPA's Science Advisory Board (SAB) and the National Academy of Public Administration (NAPA). The MITRE (1994) report, A Comprehensive Study of EPA Scientific and Technical Laboratories and Their Facilities and Capabilities, provided extensive documentation on the laboratories and their functions, as well as an analysis of five principal options for reorganizing them. Among its findings, the MITRE report expressed concern about the lack of clear, agreed-upon mission statements for EPA, ORD, or the laboratories. It also commented on the excessive use of contract personnel at EPA laboratories, various facility and equipment problems, and the need for improvement in quality-assurance and research-planning practices. Regarding laboratory reorganization, the MITRE report concluded that the discipline-based organization of ORD's laboratories was not optimal to support the mission-based organization of the rest of the agency. It favored a functional reorganization as previously recommended in Environmental Research and Development - Strengthening the Federal Infrastructure (Carnegie Commission on Science, Technology, and Government 1992). EPA's SAB and the NAPA reviewed the MITRE report (NAPA 1994; EPASAB 1994). The SAB report generally concurred with MITRE in endorsing a variation of the Carnegie Commission model for labora-

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices neers in ORD who are highly qualified; perform first-rate research; publish in peer-reviewed journals; and participate actively in professional societies, advisory panels, and university faculties. The committee 's site visits to ORD laboratories and centers were especially encouraging in that regard, and the committee strongly concurs with the judgments expressed by ORD's BOSC (EPABOSC 1998a-e) concerning the substantial number of highly capable and productive staff members in the ORD laboratories and centers. Yet, the maintenance and proper support of a first-rate scientific and technical work force have always posed difficult challenges for EPA. The ORD work force is aging. More than 47% of ORD's employees are 50 years old or older, and more than 550 ORD employees will be eligible to retire within the next 5 years. Periodic EPA hiring freezes, combined with intense scientific and technical job-market competition from the private sector and academic institutions, are making it extremely difficult for ORD to recruit the new talent needed to sustain and enhance its research work force. Safeguarding the Future: Credible Science, Credible Decisions (EPA 1992) concluded that an inadequate infrastructure and lack of long-term support have limited EPA's ability to attract and retain outstanding scientists, and that EPA did not yet have the critical mass of such scientists needed to make EPA science generally credible to the broader scientific community. The 1992 report recommended continued attention to appropriate science and science-management career tracks – research career tracks for scientists in ORD, and career tracks for scientists in the agency's program and regional offices that are similar to those for agency attorneys. It emphasized that the criteria for scientific promotion in EPA should include evidence of continuing advancement in a scientific discipline, such as completion of coursework, receipt of board certification, publications in the scientific literature, and contributions to the work of scientific organizations. The report recommended that a panel of scientists from universities and other agencies regularly evaluate the productivity of EPA scientists as a requirement for promotion within the agency. It urged that compensation for EPA scientists be based on competition with the best of their peers. It emphasized the need to minimize the bureaucratic duties of scientists and to ensure that they spend a significant percentage of their time on scientific activities. The report also recommended increased contact and enhanced

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices rotational opportunities to enable EPA scientists to participate in the broader scientific community, including participation in academic organizations, professional society activities, industry, and other federal agencies. It also recommended rotational opportunities for non-EPA scientists to work in EPA science programs. The 1992 report recommended that ORD recruit and make a long-term commitment of support for four to six research scientists and engineers with world-class reputations in areas vital to EPA's long-term strategy and direction. The panel envisioned that these eminent scientists and engineers would serve as examples and mentors for all scientists in EPA and would bring access to networks of world-class scientists to benefit the agency. The panel recommended that EPA's Science Advisory Board be asked to form a search committee. In a self-study report prepared for ORD's BOSC, the Effects Laboratory identified expanded appointment authority to attract and retain high-quality professionals as one of its greatest needs (EPABOSC 1998a). It expressed concern about its ability to compete with industry and academia in some areas. The Effects Laboratory expressed support for ORD's postdoctoral program and suggested the creation of a mechanism similar to the Senior Scientific Leadership Corps created by Congress for the Department of Health and Human Services. Because of rapid scientific advances, EPA has a continuing need to reassess its research skill base and increase its scientific and engineering capabilities in many areas, such as epidemiology, molecular toxicology, and industrial ecology. Economics and the social sciences are also of critical importance to EPA, especially in cost-benefit analysis and other decision-making aids. During the 1970s and early 1980s, ORD had an active in-house program of economic and social-science research, including both methodological development and applied studies. In 1983, this program and the resources supporting it were transferred to EPA's policy office; the budget for that program diminished considerably and was recently eliminated. ORD has continued to fund extramural economic and social science research at a modest level through its competitive grants program, and the policy office and EPA regulatory offices perform some economic studies, but EPA's inhouse program in economics and social-science research has diminished from approximately 30 ORD staff members in the 1970s to an almost entirely grants-based extramural program today. During the

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices 1980s, EPA's policy office performed an economics oversight role for the agency through its regulatory impact-analysis function, but that role has since diminished. ORD's graduate and postdoctoral fellowship programs have become an outstanding asset to the agency. This program is helping to develop the next generation of environmental scientists and provides valuable new talent to ORD's national laboratories. To prevent future shortages of environmental science and engineering personnel in critical disciplines, the federal investment in education programs should generally keep pace with overall research and development needs. Thus, EPA's fellowship program should emphasize specialities for which there is evidence of strong current and future demands. For example, in certain areas of specialization in toxicology, the current disparity between supply and demand is acute. Neurotoxicologists and genetic toxicologists who work on environmental problems are in short supply. The availability of social scientists adequately prepared for environmental research is also severely limited. EPA's fellowships program should emphasize disciplines such as these. The committee recognizes that estimation of future research work force needs and projected resources can be difficult in disciplines related to environmental protection and environmental health. Estimates can be made, however. Trends in job placements, the number of people completing educational requirements in individual disciplines, and the public and private funding for environmental programs should be among the factors in determining the scope, emphasis, and priority specialization areas for educational support through EPA's graduate-student fellowship program. In its 1995 reorganization, ORD sought to reverse the trend of previous years in which many in-house research scientists and engineers in ORD laboratories were increasingly spending their time as administrators of extramurally funded projects at the cost of doing less and less in-house research. The primary concern was that EPA's laboratories were losing their expertise and abilities to perform first-rate research. As one ORD employee put it (Budde 1997), In the early days of federal environmental research at EPA, government research scientists and engineers worked with their technicians in laboratories and pilot plants. It was hands-on R&D, and these people had the respect of their scientific colleagues in academia and industry.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices As Congress passed one after another piece of environmental legislation, with daunting requirements and timetables, it provided EPA with ever growing quantities of extramural research money instead of authorization to hire more federal scientists and engineers. EPA research scientists and engineers were offered promotions, power, and influence by becoming administrators of money instead of leaders of science and engineering. The few new hires were almost always managers or administrative support people. Gradually over the past 15 or more years, most EPA research scientists and engineers became money managers and administrators. EPA research by its own federal staff was ignored and even discouraged by management, and so it was effectively destroyed except in a few isolated pockets. Spending the big extramural bucks received all the attention. In addition, concerns were heard about favoritism and poor oversight by ORD laboratory personnel in the administration of some externally funded projects. To change that, the agency centralized much of its extramural research funding in a rigorously competitive STAR grants program, and it sent a strong message to in-house laboratory staff that they would be expected to do more research and less administration, and that they would be judged mainly by research accomplishments in the future. One of the nine strategic principles established by ORD states, “Through an innovative and effective human resources development program, nurture and support the development of outstanding scientists, engineers, and other environmental professionals at EPA.” In a 1996 workshop involving a cross-section of staff from ORD's laboratories, centers, and offices (EPA 1997a), participants identified the following general work-force-support needs to be of the highest priority: Reduce red tape – Empower staff by reducing unnecessary paperwork. Communications – Develop and implement a comprehensive communications plan to improve two-way communication and make electronic communications more effective within ORD. Career advancement and development – Provide career enhancement opportunities for all employees. Resources and infrastructure – Define “infrastructure” and provide adequate resources to support science.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices To address those issues and others, ORD established a Human Resources Council in 1996. Chaired by an ORD laboratory director, the council has 25 members representing staff from each ORD office, center, and laboratory, with at least one representative from each geographical location, as well as representatives from the agency's human resources office, labor unions, and civil rights office. One of the most important goals of the Human Resources Council should be to help managers within ORD identify ways to improve and maintain staff morale. Achieving and maintaining good morale are essential to EPA, whose future is inevitably affected by the zeal and confidence with which the staff carries out its work. Good morale is difficult if not impossible to define, however. It might be observed through the pride of employees in being identified with the agency and their pleasure in working for it, but perhaps the most obvious way to recognize morale, like health, is when it is damaged. Staff morale is a fragile thing, and motivational systems that are improperly devised or administered can damage it. The committee was pleased to observe in its laboratory site visits that ORD has many competent and dedicated scientists, engineers, and other staff. At times, however, many ORD staff have been discouraged and pessimistic about the future of ORD and frustrated and uncertain about prospects for their own professional careers within ORD. The concerns heard by our committee were many: too much disruptive change in budgets, priorities, and policies, often crisis-driven; excessively bureaucratic procedural hurdles; too many scientifically underqualified administrators instead of research scientists managing laboratory programs; failure to replace departing scientists and technicians with new talent in a timely manner; lack of trust up and down the management chain; institutional faultfinding and paranoia; inadequate travel funds and other infrastructure support for nonmanagerial scientists; lack of explanations for decisions; unkept promises; criticism from Congress and others; pessimism that anyone will listen or be able to help. Undoubtedly, some of these complaints reflected individual problems, and ORD management has taken steps to address some of them. But feedback is a valuable commodity, and it pays to keep listening. The committee offers the following observations and recommendations for developing and supporting the scientific work force.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices Continuity Over EPA's 30-year history, the priorities, initiatives, and operating policies of ORD have often changed sporadically in response to shifting agency demands, the goals and priorities of different administrations, and congressional mandates. Although the much-decried “pollutant-of-the-week ” syndrome might be an overstatement, “priority-of-the-year” is close enough to the truth to be of concern in a research program. The sporadic character of research funding for major air pollutants is an example (Powell 1999). Too often, research on a particular pollutant becomes a high priority a year or two before a National Ambient Air Quality Standard is to be evaluated – usually too late for long-term studies. Then, after the agency has made a decision, administrative interest wanes and work is curtailed, despite the certainty, embodied in the Clean Air Act requirement for a re-evaluation every 5 years, that another cycle of interest will soon begin. Research programs require the development of scientific and engineering talent, experience, and infrastructure. They cannot be turned off and on rapidly. Research requires a longer time scale than non-scientists often appreciate. A lack of stability in goals, priorities, practices, structure, or funding can be especially harmful to a research organization. ORD's historical lack of stability and sometimes disruptive changes have been attributed to growth in EPA's legislative mandates and priorities; specific directives from Congress in the appropriations process; changes in political administrations; changes in public attitudes; lawsuits and court decisions affecting regulatory programs and associated scientific needs; pressures from public groups or regulated parties; inadequate budgets to meet competing demands; recommendations from outside groups; and changes in the leadership of ORD. The limited financial and human resources of ORD should be managed with a steady hand and a clear and persistent vision of how to maximize the gains in scientific understanding from ORD's budget and the creative time and energy of its staff. ORD should try to refrain from making abrupt shifts in research priorities or internal processes. It should seek feedback and consultation from staff at all levels and provide timely fore-warning when changes will be needed regarding in-house or extramural research budgets, responsibilities, organizational structure, or priorities for research projects, programs, and funding mechanisms.

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices Bureaucracy ORD and EPA should make a special effort to resist a tendency commonly seen in large institutions to impose cumbersome bureaucratic procedures in response to management concerns. Institutional paranoia, fault-finding, and fear of possible fault-finding can paralyze and demoralize an organization. Excessively bureaucratic procedures are antithetical to a creative research program with high standards of quality, efficiency, and teamwork. ORD should frequently examine itself to identify and eliminate excessive bureaucratic safeguards, administrative hurdles, redundant requirements for approvals at multiple levels of management, and other bureaucratic impediments. Research leaders at all levels in ORD should strive to minimize bureaucratic impediments, provide timely responses to requests from other organizations and from staff scientists and engineers, and place high priority on finding ways to increase flexibility in getting research done. ORD managers throughout the organization should be given the authority and resources to make decisions at the lowest appropriate level of management, provided that such decisions are compatible with EPA policies and ORD's strategic goals and budget priorities. Decisions that fit within this category include problem selection and program definition; acquisition of most equipment and supplies, personnel assignment; attendance at scientific meetings; inviting and supporting a visiting scientist; and granting permission for ORD scientists to work for a time in another laboratory in this country or abroad. Staff Development An organization that does not adequately aid the continuing improvement of its employees is remiss in its responsibilities and in the long run handicaps itself. Continuing career development for ORD's research staff is critical to the quality and productivity of their research. Opportunities for professional development are especially important for ORD scientists and engineers who, in the 1995 reorganization of ORD discussed earlier in this chapter, were asked to return to research after functioning as managers of extramurally funded projects. In addition to in-service training, career development includes participation in professional society meetings and activities, as well as col-

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices laboration with scientists in other federal agencies, research centers, and universities. The Individual Development Plan (IDP) seems to receive wide support in ORD. The IDP is negotiated between each employee and supervisor. It addresses career paths, training, and rotational goals. The committee also recommends that ORD expand its programs for intellectual growth and exchange with other research organizations. Additional resources are needed for travel to scientific meetings and collaboration with scientists in distant laboratories inside and outside EPA. There is widespread dissatisfaction among ORD research staff with the lack of travel support to enable such interactions. The lack of such support inhibits their ability to share their results with the scientific community at large through participation in conferences and workshops and to develop and sustain meaningful scientific collaborations with scientists at other institutions. Mentoring of junior staff – scientific and support staff alike – is another key element of a successful research program. The committee observed many elements of a mentoring program in ORD's laboratories. The committee recommends that ORD establish a more formal mentoring program to promote professional growth of all of its junior staff. The committee recommends that ORD increase sabbatical assignments for ORD researchers to gain experience in other scientific organizations, and that ORD bring more scientists from universities, other government agencies, and private organizations to ORD laboratories and centers for visiting appointments. Recruitment The long-term success of EPA's research and development program depends on a staff of well-trained, creative scientists, engineers, and other professionals. Personnel policies affecting the recruitment, retention, and support of research personnel at ORD are critical. ORD often has not provided recruitment and retention packages for research scientists and engineers that are competitive with those of other research organizations in academe or industry. While federal personnel policies impose limits and difficulties, the difficulties can be overcome, as demonstrated by the strong in-house research programs of NIH and NIST. In 1989, ORD instituted a new program for the recruitment and pro-

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices motion of a limited number of nonmanagerial, senior scientific and technical research and development staff at its laboratories and centers. ORD currently has eight scientists and engineers serving in such positions, which are called “ST” positions. Individuals in those positions are paid at Senior Executive Service levels, and recruitment bonuses up to 25% of annual salary are allowable. No managerial duties are required in these research positions. ORD instituted a special board and has additional experts on an ad hoc basis to review the scientific and technical qualifications of both in-house and external candidates and the performance of individuals in such positions. The board includes senior staff from the ORD laboratories and centers, as well as outside scientists and engineers who are typically at the level of full professor. In fiscal year 1999, ORD promoted four in-house research scientists to ST positions. EPA has also established an excellent fellowships program, which is intended to revitalize the ORD work force through an infusion of young scientists and engineers. Fellows are selected through a merit-based, competitive process in targeted scientific and technical disciplines relevant to needs identified by ORD. They are generally appointed for 3-year terms, with salaries ranging from about $40,000 to $60,000 per year, full employee benefits, and relocation expenses. ORD advertises the program through professional scientific societies, university graduate departments, scientific periodicals, and EPA 's web site. In fiscal year 1999, ORD sought candidates in water resources engineering and management; urban and regional planning; environmental science; chemistry; biology (e.g., cell, developmental, molecular, reproductive, neurobiology, and animal and plant physiology); biochemistry; physical chemistry; human health sciences; endocrinology; epidemiology; pharmacology; toxicology, population and community modeling; geography; microbiology; hydrology; ecology (e.g., aquatic, coastal systems, coral, ecosystem, estuarine, landscape, marine, and microbial); ecotoxicology; meteorology; applied mathematics and statistics; systems analysis; computer science; geographic information science; geomorphology; geostatistics; genetics; immunology; environmental, chemical, and biomedical engineering; and other disciplines. In the first year of the program, ORD was swamped with nearly 2,500 applications for 100 available fellowships. In 1999, ORD received 1,061 applications for 50 available positions. ORD placed 47 applicants in the laboratories, including 15 at the Effects Laboratory, 21

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices at the Exposure Laboratory, and 11 at the Risk Management Laboratory; and 3 went to ORD's Assessment Center. The 50 included 28 women and 10 minority fellows. In fiscal year 2000, ORD received 798 applications but was only able to hire 16 candidates due to an agency hiring freeze. Leadership Criteria for the selection and advancement of research managers in ORD should emphasize persons who are accomplished scientists in their own right and have the ability to select, inspire, lead, and otherwise encourage other scientists and engineers to succeed in meeting agency research needs by pushing back the frontiers of understanding in their fields of special competence. The following criteria are suggested: Accomplishments in original scientific research, demonstrated by publication in refereed scientific or engineering journals. Demonstrated ability to develop and implement high quality scientific and engineering research projects and programs relevant to agency and national needs. Credibility and reputation in the scientific community. Ability to select, inspire, and lead scientists and engineers to further their professional development by increasing their scientific and technical competence and their ability to summarize and add to the policy-relevant scientific and engineering knowledge needed by EPA and the nation. Ability to communicate research needs, plans, and results to policy-makers, Congress, the scientific community, stakeholder groups, and the public. Research managers in ORD should be scientifically and technically accomplished, but they should also be capable administrators and personnel managers. The selection of capable people, their support and development, and sometimes their discharge are among the most important tasks any ORD supervisor should perform. Failure to take the time to choose wisely in the first place or to work as long and as patiently as it takes to help a miscast employee move into a better role

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Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices within the research program, or out of the office altogether, can result in more lost time and declining public support than virtually any other mistakes. Leaders in ORD should consult regularly with, and be perceived to seek and consider advice from, the scientists and engineers within ORD. Research managers in ORD should be selected on the basis of scientific competence and the personnel skills needed to lead and nurture professional development of their staff scientists and engineers. Our committee's vision for the future of EPA's research program requires leaders who have technical competence; managerial abilities; communication skills; knowledge and skills in research planning and administration and in the public decision process, including its political dimensions; and the ability to marshal constituencies for an effective research program. The issue of scientific leadership is discussed further in the last chapter of this report.